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Home My WebLink AboutDERR-2024-011666 Fifth Five-Year Review Report for Murray Smelter Superfund Site Murray, Salt Lake County, Utah Prepared By: Utah Department of Environmental Quality Division of Environmental Response and Remediation For U.S. Environmental Protection Agency Region 8, Denver, CO --------------------------------- Aaron Urdiales, Director Superfund and Emergency Management Division AARON URDIALES Digitally signed by AARON URDIALES Date: 2024.08.14 08:20: 17 --06'00' i Table of Contents LIST OF ABBREVIATIONS & ACRONYMS .........................................................................................ii I. INTRODUCTION ................................................................................................................................... 1 FIVE-YEAR REVIEW SUMMARY FORM ......................................................................................... 3 II. RESPONSE ACTION SUMMARY...................................................................................................... 3 Basis for Taking Action.......................................................................................................................... 3 Response Actions .................................................................................................................................... 5 Status of Implementation ........................................................................................................................ 7 Remedy Implementation ......................................................................................................................... 8 III. PROGRESS SINCE THE LAST REVIEW ....................................................................................... 10 IV. FIVE-YEAR REVIEW PROCESS .................................................................................................... 11 Community Notification, Involvement & Site Interviews .................................................................... 11 Data Review.......................................................................................................................................... 12 Site Inspection....................................................................................................................................... 13 V. TECHNICAL ASSESSMENT ............................................................................................................ 13 QUESTION A: Is the remedy functioning as intended by the decision documents? .......................... 13 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? .............................................. 14 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? ............................................................................................................... 15 VI. ISSUES/RECOMMENDATIONS..................................................................................................... 16 OTHER FINDINGS.............................................................................................................................. 17 VII. PROTECTIVENESS STATEMENT ................................................................................................ 18 VIII.NEXT REVIEW ............................................................................................................................... 18 APPENDIX A – REFERENCE LIST....................................................................................................... 19 APPENDIX B- SITE MAPS .................................................................................................................... 20 APPENDIX C- PUBLIC NOTICE AND COMMUNITY INTERVIEWS .............................................. 25 APPENDIX D- SITE INSPECTION CHECKLIST AND PHOTOS....................................................... 32 Tables Table 1 - Contaminants of Concern/ Environmental Media……………………………………………… 4Table 2 - Summary of Planned and/or Implemented ICs……………………………………………….. 9Table 3 - Protectiveness Determinations/Statements from the 2019 FYR……………………………… 10Table 4 - Status of Recommendations from the 2019 FYR……………………………………………... 10 ii LIST OF ABBREVIATIONS & ACRONYMS ACL Alternate Concentration Limit AOC Administrative Order on Consent BHHRA Baseline Human Health Risk Assessment CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminant of Concern DWQ Division of Water Quality EE/CA Engineering Evaluation/Cost Analysis EPA U.S. Environmental Protection Agency ERA Ecological Risk Assessment FYR Five-Year Review IC Institutional Control IHC Intermountain Health Center ug/L Micrograms per Liter mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter MCL Maximum Contaminant Level MNA Monitored Natural Attenuation MOU Memorandum of Understanding NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Operations & Maintenance PS Performance Standard RA Remedial Action RAO Remedial Action Objective RDR Remedial Design Report ROD Record of Decision SAP Sampling Analysis Plan Site Murray Smelter Superfund Site SSOD Smelter Site Overlay District Trust ASARCO Multi-State Environmental Custodial Trust UDEQ Utah Department of Environmental Quality UTA Utah Transit Authority 1 I. INTRODUCTION The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them. The U.S. Environmental Protection Agency (EPA) is preparing this five-year review pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy. This is the fifth FYR for the Murray Smelter Superfund Site (Site). The triggering action for this statutory review is the completion of the fourth FYR in August 2019. This FYR report has been prepared because hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure. There were no Operable Units defined in the Record of Decision (1988). Therefore, the entire Site will be reviewed in this document. The Murray Smelter Superfund Site Five-Year Review was led by Maureen Petit, Environmental Scientist for UDEQ. Participants included Dave Allison (UDEQ), Scott Everett (UDEQ), and Sydney Chan (EPA). Site Background The Murray Smelter Site is in Murray, Salt Lake County, Utah. The Site includes the former operational areas of the Murray Smelter and adjacent Germania Smelter, which are referred to as the on-facility area, as well as surrounding residential and commercial areas. These surrounding areas are referred to as the off-facility area, where air dispersion and deposition modeling indicated airborne emissions from the smelters impacted the environment or where contamination in shallow ground water may be transported to in the future. The on-facility area is approximately 142 acres. Its boundaries are 5300 South Street to the south, State Street to the east, Little Cottonwood Creek to the north, and the west set of the Denver & Rio Grande Western railroad tracks to the west. The off-facility area is approximately 30 acres west of the on- facility area, approximately 106 acres south and southeast of the on-facility area, and a small area between 5200 South Street and Little Cottonwood Creek east of the on-facility area. The west portion of the off-facility area is bound by Little Cottonwood Creek to the north, 300 West Street to the west, 5300 South Street to the south, and the on-facility boundary to the east. The south/southwest portion is On January 17, 2024, the EPA issued Updated Soil Lead Guidance for CERCLA sites and RCRA Corrective Action Facilities that lowered recommended regional screening levels for lead-contaminated soil. The EPA and UDEQ/DERR will evaluate how this change may impact the cleanup that was conducted at the Murray Smelter Superfund site and determine if additional investigation and/or cleanup is needed. The EPA and UDEQ/DERR will share information on planned activities and results as they become available. 2 bounded by 5300 South Street to the north and Wilson Avenue to the south. See Figure 1 for Site boundaries. The boundaries of the off-facility area are based on the results of air dispersion modeling performed in November 1994. The purpose of the modeling was to identify the area that potentially would have received the greatest amounts of deposition resulting from lead and arsenic emissions from the Murray Smelter during its operating period. The small off-facility area between 5200 South Street and Little Cottonwood Creek east of the on-facility area was added in 1998 to encompass the shallow groundwater flow path from the former baghouse area to its discharge into the creek. Surface water at the Site is represented by Little Cottonwood Creek, a perennial stream that flows along the north/northeast boundary of the Site and discharges into the Jordan River approximately one mile downstream of the Site. Groundwater at the Site is comprised of three distinct aquifers: The shallow aquifer is unconfined with a saturated thickness ranging from 2.5 feet to 25 feet. The average water depth is approximately ten feet. Shallow groundwater flows generally north- northeast toward Little Cottonwood Creek. The intermediate aquifer is separated from the shallow aquifer by the Bonneville blue clay that is continuous across the Site. Beneath the Bonneville blue clay, the intermediate and deep aquifers are separated by more than 200 feet of inter-bedded, fine- and coarse-grained, silty clay and alluvial deposits. Groundwater in the intermediate aquifer flows north-northwest across the Site, and the intermediate aquifer is not hydraulically connected to surface water bodies in the vicinity of the Site. The deep aquifer located several hundred feet below the intermediate aquifer is the main source of drinking water for most residents in the Salt Lake Valley. • • • 3 FIVE-YEAR REVIEW SUMMARY FORM II. RESPONSE ACTION SUMMARY Basis for Taking Action The Site Characterization Report completed by Hydrometrics in 1996 determined that metal concentrations were elevated in soils primarily due to the presence of residual smelter materials (on- facility area) and deposition of smelter emissions during the period of operation (off-facility area). The report identified lead and arsenic as the primary Contaminants of Concern (COCs) in the on-facility area soils and lead in the off-facility soils. The report also identified that shallow groundwater within the on- facility area was contaminated with arsenic and selenium. Elevated arsenic concentrations were also measured in Little Cottonwood Creek (surface water). The Site Characterization Report (August 1996) and the Baseline Human Health Risk Assessment (BHHRA) (May 1997) identified four types of smelter material within the on-facility area: SITE IDENTIFICATION Site Name:Murray Smelter EPA ID: UTD980951420 Region: 8 State:UT City/County: Murray/Salt Lake County SITE STATUS NPL Status:Proposed Multiple OUs? No Has the site achieved construction completion? Yes REVIEW STATUS Lead agency: State [If “Other Federal Agency”, enter Agency name]: Author name (Federal or State Project Manager): Maureen Petit Author affiliation:Environmental Scientist, UDEQ/DERR Review period:8/31/2023 - 4/15/2024 Date of site inspection: 9/13/2023 Type of review: Statutory Review number:5 Triggering action date: 8/14/2019 Due date (five years after triggering action date): 8/14/2024 4 Category I Material. Residual smelter material associated with the arsenic trioxide production process consisting of relatively undiluted flue dust. This material contained the highest arsenic concentrations (highest concentration approximately 760,000 milligrams per kilogram (mg/kg)), was present in relatively small volumes (approximately 580 tons), and was associated with distinctly elevated arsenic concentrations in underlying shallow groundwater. Category I material was identified as posing a potential health risk and was considered by the EPA to be principal threat waste and a major source of arsenic in shallow groundwater. Category II Material. Residual smelter material associated with smelter flue dust operations (blast furnace flues, baghouse, roasting plant flues and Cottrell electrostatic precipitator) and consisting of diluted flue dust mixed with soil, new fill or debris from former smelter flues. This material contained lower arsenic concentrations than Category I material (average of approximately 9,000 mg/Kg) but was present in larger quantities (approximately 90,000 cubic yards). Category II material was identified as posing a potential direct contact health risk and as being a source of arsenic to groundwater. Category III Material. Residual smelter material and contaminated soils that contained arsenic or lead at levels predicted to pose an unacceptable health risk to site workers within the on-facility area (arsenic greater than 1,200 mg/kg or lead greater than 5,600 mg/kg) but were not sources of arsenic to groundwater. Category IV Material. Smelter slag that was present primarily in the northern portion of the on- facility area and contained relatively high levels of lead (typically in the range of 8,000 to 16,000 mg/kg) in a physical form (vitrified iron silicate) that limits the release of metals. Slag was found not to be a source of metals to groundwater or surface water. Human health risks associated with exposure to slag under a commercial/light-industrial scenario were predicted to be within EPA acceptable risk range. The slag may have the potential to release metals over the long term if the vitrified material breaks down due to weathering. The COCs that have been released at the Site in each environmental media are summarized in the following table. Table 1:Contaminants of Concern/ Environmental Media Contaminants of Concern Environmental Media Lead and arsenic Surface soil, subsurface soil and dust Lead, arsenic and selenium Groundwater within on-facility area Aluminum, arsenic, cadmium, lead and zinc Surface water in Little Cottonwood Creek Aluminum, arsenic, cadmium, copper, lead, mercury, nickel, selenium, silver, thallium and zinc Sediment in Little Cottonwood Creek The EPA identified lead and arsenic as the COCs for human exposure and aluminum, arsenic, cadmium, copper, lead, mercury, nickel, selenium, silver, thallium and zinc as the COCs for ecological receptors. • --------- • --------- • ---------- • 5 The Baseline Ecological and Human Health Risk Assessments provided the basis for the EPA’s decision that a Remedial Action (RA) was necessary at the Site. Elevated and unacceptable risks were identified for both human and ecological receptors. Risks to humans: unacceptable risks to current and future non-contact intensive workers, current contact intensive workers, and current and future residents via ingestion of arsenic and lead in dust and soil and ingestion of arsenic in groundwater. Risks to ecological receptors: exposure to lead in soils and sediment, selenium in plants. Response Actions Initial Response The Site was proposed for the National Priorities List in January 1994, but the listing was never finalized at the request of the City of Murray with concurrence from EPA and UDEQ. ASARCO agreed to perform an engineering evaluation/cost analysis (EE/CA) pursuant to the terms of an Administrative Order on Consent (AOC) (EPA, 1995). ASARCO initiated the EE/CA with investigations performed between April 1995 and February 1996. In September 1995, the EPA and ASARCO entered into a separate AOC for a time-critical removal action at a playground located in the Grandview Trailer Park within the on-facility area. Soils contaminated by lead and arsenic were excavated within and adjacent to the playground. The playground was backfilled with clean fill. This removal action was completed in November 1995. In 1997, the EPA redirected what had been a non-time-critical removal action into the remedial action framework. ASARCO’s obligation under the AOC to perform an EE/CA was changed to a feasibility study, which was completed by ASARCO in August of 1997 (MFG, 1997). In April 1996, the EPA and Murray City signed a Memorandum of Understanding (MOU) creating a formal role for Murray City in the assessment of potential land uses at the Site, the development of cleanup options, and the implementation/enforcement of institutional controls. To facilitate the development of an acceptable remedy for the on-facility area, the EPA and UDEQ initiated the formation of the Murray Smelter Working Group (Working Group) in October 1996. The Working Group included the EPA, UDEQ, Murray City and ASARCO, along with land and business owners within the on-facility area. The purpose of the Working Group was to inform the EPA and UDEQ about pending redevelopment plans and to provide a forum for discussing alternative cleanup strategies for the on-facility area. A commitment was made by the Working Group to integrate future remedial actions with redevelopment activities. Agreements among the members of the Working Group were incorporated in an Agreement in Principle signed in May 1997. Selected Remedies The 1998 Record of Decision (ROD) selected a remedy to address the unacceptable risks posed to current and future human populations and ecological receptors identified in the BHHRA. The Ecological Risk Assessment (ERA) evaluated potential exposures to fish, birds, mallard ducks, frogs and pocket • • • • • • 6 gophers to COCs within likely habitat areas. Observation of the ecological receptors at the Site, in the form of qualitative surveys, documented in the ERA suggests that the predicted effects are not occurring. Given that the remedy for the Site includes capping of all exposed surface areas, including wetlands, no ecological mitigation was warranted. Remedial Action Objectives The overarching Remedial Action Objective (RAO) is to develop a comprehensive remedy that protects human health and the environment, is consistent with the current and anticipated future land use and removes obstacles to Site development associated with real or perceived environmental contamination. The RAOs for the on-facility area are as follows: Soil/Smelter Material: Prevent unacceptable risks to current and future workers or ecological receptors due to the ingestion of on-facility soil/smelter materials containing arsenic or lead. The remediation levels for soil/smelter material in the on-facility area are 1,200 mg/kg arsenic as the 95% upper confidence limit on the arithmetic mean and 5,600 mg/kg lead as the arithmetic mean within any given exposure unit. Groundwater: Minimize future transport of arsenic from source materials to the shallow aquifer, prevent exposure of human and ecological receptors to groundwater with arsenic concentrations that represent an unacceptable risk, and prevent unacceptable increases in the arsenic concentrations within the intermediate aquifer resulting from arsenic migration from the shallow aquifer. The remediation levels for groundwater are: o Meet the Maximum Contaminant Level (MCL) of 0.05 milligrams per liter (mg/L) for dissolved arsenic in the shallow groundwater at the east and west Site boundaries; o Meet the MCL of 0.05 mg/L for arsenic in the intermediate aquifer; and o Meet the Alternate Concentration Limit (ACL) of 5.0 mg/L for dissolved arsenic within the unconfined shallow aquifer within the Site boundaries. Surface Water/Little Cottonwood Creek: Protect Little Cottonwood Creek water quality by preventing unacceptable increases of arsenic concentrations in surface water resulting from groundwater discharges or surface water run-off from the Site. The remediation levels for Little Cottonwood Creek surface water are: o Meet the Division of Water Quality (DWQ) standards for waters of the state for trivalent arsenic of 190 micrograms per liter (ug/L) as a four-day average and 360 ug/L as a one-hour average; and o Meet the DWQ standard for waters of the state for dissolved arsenic of 100 ug/L. The RAOs for the off-facility area are as follows: Prevent unacceptable risks to current and future residents due to the ingestion of soil containing lead and prevent unacceptable risks to current and future non-contact, intensive workers due to the ingestion of soil containing lead. The remediation levels for off-facility soils are: The concentration of lead in surface soils within residential areas shall not exceed 1,200 mg/kg as the arithmetic mean within any given residential property; and • • • • 7 The concentration of lead in surface soils within commercial areas of the site shall not exceed 5,600 mg/kg as an arithmetic mean within any given commercial property. Status of Implementation Selected Remedy for On-Facility Area The selected remedy for the on-facility area was source control and Monitored Natural Attenuation (MNA) to achieve the RAO for on-facility groundwater, barrier placement to achieve the RAO for on- facility soil/smelter materials, and institutional controls. The main components of the remedy for the on- facility area were as follows: Category I material. Excavation and off-site disposal of approximately 800 tons of Category I material considered principal threat waste. This material was transported to a permitted hazardous waste treatment, storage, and disposal facility. Category II material. Excavation and on-site consolidation of approximately 63,000 cubic yards of low-level threat waste. The excavated Category II material was consolidated in a fully encapsulated repository system constructed within the Site boundaries and acts as a barrier to prevent direct contact. The repository was designed as the base for a new access road through the Site. The selected remedy includes Operations & Maintenance (O&M) of the onsite source control (repository) system with Site development over the repository. Category III material. The covering of Category III materials in place, with barriers to prevent direct contact. Such barriers may include pavement, landscaping, soil caps or sidewalks. Category IV material. Although no unacceptable risks associated with exposure to slag were identified by the EPA, Site development resulted in the construction of barriers over the slag ensuring no exposure to slag in the future. Groundwater. MNA shall continue until shallow groundwater achieves the ACL for dissolved arsenic of 5.0 mg/L. The intermediate aquifer will be monitored to determine compliance with the MCL for dissolved arsenic of 0.05 mg/L. Surface water. Monitoring of surface water in Little Cottonwood Creek to ensure continued compliance with applicable water quality standards. Institutional Controls. The remedy also included institutional controls (ICs). ICs were adopted as a Murray City ordinance establishing a Smelter Site Overlay District (SSOD) for the on- facility area and restrictive easements that run with the land. The SSOD prevents residential and contact-intensive industrial land use and requires maintenance of the barriers and controls over the Category II, Category III, and Category IV materials. The restrictive easements prohibit the construction of new wells or use of existing wells within the on-facility area and • • • • • • • • 8 the western and eastern portions of the off-facility area, except for EPA-approved monitoring wells. Selected Remedy for Off-Facility Area For the off-facility area, the selected remedy was the removal of soil to 18 inches in depth with lead levels exceeding 1,200 mg/kg in residential yards or with lead levels exceeding 5,600 mg/kg in commercial areas and replacement with clean fill. The excavated soil was used as sub-grade material during the construction of the repository. Remedy Implementation Remedial action (RA) activities began in August 1998 and were completed in February 2001 in accordance with the ROD and the Consent Decree. RA activities were performed on an accelerated schedule to meet a series of interim deadlines to facilitate redevelopment. Excavation and off-site disposal of Category I material was completed in August 1998. RA activities at the current Utah Transit Authority (UTA) park-and-ride facility were conducted between 1998 and May 1999. The work included the removal of Category II materials, construction of a portion of the lined repository system, and consolidation of Category II materials within the repository. Construction of the repository system beneath Cottonwood and Woodrow Streets, which bisect the western side of the site, was conducted between September 1998 and November 1999. Concurrent with this effort, construction of the Southwest Repository Extension began in October 1999 and was completed a year later. Groundwater monitoring wells were installed in October 2000. In addition to the RA activities, a removal action was conducted in August 2000 to demolish the smelter smokestacks in the on-facility area. A memorial garden was later constructed on the landscaped grounds of the Intermountain Health Center (IHC) where the largest stack once was located. The installation of three shallow groundwater monitoring wells (MW-10, MW-11, and MW-12) was delayed until 2005 due to the construction of Costco and Intermountain Medical Center located in the on-facility area. In the off-facility area, soil from 12 properties with average lead concentrations greater than 1,200 mg/kg was removed and replaced with clean fill. No ICs were established for the off-facility area at the time of the RA. 9 IC Summary Table Table 2: Summary of Planned and/or Implemented ICs Media, engineered controls, and areas that do not support UU/UE based on current conditions ICs Needed ICs Called for in the Decision Documents Impacted Parcel(s) IC Objective Title of IC Instrument Implemented and Date (or planned) Soil Yes Yes On-Facility Land use restrictions Smelter Site Overlay District (SSOD) April 1998 Groundwater Yes Yes On-Facility Prohibit construction of new wells or use of existing wells SSOD April 1998 Restrictive Easements August 2000 In accordance with the ROD, Murray City created the SSOD with the passage of Ordinance 98-07 on April 14, 1998, and subsequently hired a development site coordinator to oversee the SSOD. The SSOD established the necessary public and private ICs to protect human health and the environment from the remaining contamination in the on-facility area of the Site and to protect the integrity of current and future barriers/caps. The SSOD specifically requires a development permit to be obtained that includes a grading and drainage plan; monitoring and maintenance plan to ensure all caps and barriers will be maintained; and prohibits the use of existing wells or construction of new wells. Systems Operations-Operation & Maintenance ASARCO originally developed the Operations and Maintenance (O&M) Plan, which became final in July 2003. The O&M Plan includes all requirements for O&M of the on-facility repository system and other on-facility remedial components including repository barrier maintenance, repository surface drainage and controls, repository settlement monitoring, and groundwater/surface water monitoring. Since December 9, 2009, the O&M Plan continues to be implemented by the settling defendants, ASARCO Multi-State Environmental Custodial Trust (Trust), Murray City, and UTA. Pursuant to the O&M Plan, bi-annual barrier inspections are conducted in May and November of each year. Murray City submits annual SSOD reports to the EPA and UDEQ that include monthly inspections of the onsite repository, development permits issued under the SSOD, and annual barrier monitoring reports from COSTCO, UTA and IHC. Annual SSOD reports were not submitted for 2021 and 2022 activities onsite due to employee turnover within Murray City. Reporting information from 2021 and 2022 has been requested from Murray City, but has not been received as of the date of this report. The Trust's contractor, Ramboll, conducts annual groundwater sampling and reporting to evaluate MNA to achieve arsenic MCLs in the shallow groundwater at the east and west Site boundaries; MCLs in the 10 intermediate aquifer; and the ACL for arsenic within the unconfined shallow aquifer within the on- facility boundaries. The annual reports include a statistical evaluation which is used to determine the effectiveness of source control activities (encapsulated repository and barriers) and natural attenuation relative to the performance standards described by the Remedial Design Report (RDR) and the Sampling and Analysis Plan (SAP). III. PROGRESS SINCE THE LAST REVIEW This section includes the protectiveness determinations and statements from the last five-year review as well as the recommendations from the last five-year review and the current status of those recommendations. Table 3: Protectiveness Determinations/Statements from the 2019 FYR OU # Protectiveness Determination Protectiveness Statement Sitewide Short-term Protective The remedy at the Murray Smelter Superfund Site is currently protective of human health and the environment. Source control measures (repository system and barriers) are in place, are being maintained as designed, and are inspected regularly. Institutional Controls for the Site are in place with the establishment and enforcement of the Smelter Site Overlay District. The ICs effectively restrict land use and groundwater use. For the remedy to be protective in the long term, the validity of the arsenic groundwater and surface water cleanup levels needs to be evaluated. Table 4: Status of Recommendations from the 2019 FYR Issue Recommendations Current Status Current Implementation Status Description Completion Date (if applicable) MCL for arsenic changed from .05 mg/L to .01 mg/L effective January 2006. Determine if the changed MCL should be incorporated into the current remedy Addressed in Next FYR UDEQ and EPA evaluated the MCL change and agreed no change is necessary at this time. The change will be evaluated again during the next five-year review period. 8/14/2024 Aquatic Life Ambient Water Quality Criteria for arsenic changed to 0.150 mg/l (4-day average) and 0.340 mg/l (1-hour average). Determine if change in aquatic ambient water quality criteria should be incorporated into the current remedy Addressed in Next FYR UDEQ and EPA evaluated the Aquatic Life Ambient Water Quality Criteria change to determine if the new water quality criteria for arsenic should be adopted and agreed no change is necessary at this time and that change will be evaluated again during the next five-year review period. 8/14/2024 11 Issue Recommendations Current Status Current Implementation Status Description Completion Date (if applicable) Murray City did not conduct the 2018 biannual (May and November) inspection of the barrier system and did not complete the 2018 Annual Inspection Report (due to employee turnover). Discuss the SSOD expectations with Murray City. Completed UDEQ and EPA met with Murray City in February 2019 and went over the Institutional Controls and Operation & Maintenance requirements as outlined in the SSOD. 3/4/2019 Several development activities have occurred on-site under the SSOD since the last FYR. In 2019, three SSOD permits were issued to IHC. The projects included relocating the sanitary sewer piping under Building Five of the campus, installing security gates and the associated electrical conduits to a parking lot, and creating a lit walking trail along the northwest boundary of the campus. UTA was granted a permit to dig a trench to install new fiber optic lines; trenching was deemed unnecessary when it was discovered that the lines could be run through the existing electrical conduit. Costco did not apply for any SSOD permits in 2019; however, a permit was retroactively issued in early 2020 when it was discovered that soils were transported offsite to Uintah Yard in Farmington, Utah, after a freezer in the basement of the warehouse was replaced. The soils disposed of at the Uintah Yard were sampled at the request of Murray City. The material was subsequently removed from Uintah Yard and disposed of at the Salt Lake Valley Solid Waste Landfill in March 2020. Murray City issued six SSOD permits in 2020. Costco installed 18 security bollards at the entrance doors to the warehouse and had an underground fiber cable installed. IHC installed signage, fencing, and a power conduit for a pedestrian crossing, installed an underground power conduit to the traffic signal at 5300 South and Woodrow Street, and expanded the Dietary Services Building. Smelter slag was encountered during the remodel; all contaminated material was disposed of at the Salt Lake County Landfill. In 2023, UTA replaced several track switch systems along the track. IHC installed a fence around the Grandview Parking Lot and installed a sewer drain in Building Four of the campus. The IHC expansion project of the Central Lab Facility is ongoing. IV. FIVE-YEAR REVIEW PROCESS Community Notification, Involvement & Site Interviews A public notice was made available by press release in the Murray Journal on April 1, 2024, stating that there was a FYR and inviting the public to submit any comments to the EPA and UDEQ. The results of the review and the report will be made available at the Site information repository located at UDEQ. The report can be found electronically on the Site Profile Page (http://www.epa.gov/superfund/murray- smelter). A copy of the announcement is provided in Appendix C. During the FYR process, UDEQ conducted interviews to document any perceived problems or successes with the remedy that has been implemented to date. Community interviews were conducted by UDEQ 12 from March 18 through April 2, 2024. UDEQ contacted representatives from Murray City, UTA and IHC. The interviews and responses are provided in Appendix C. Data Review Groundwater monitoring is conducted on-site annually. Groundwater samples are collected from shallow (Figure 2) and intermediate (Figure 3) monitoring wells. The following is a summary of arsenic concentrations in the groundwater from the most recent sampling event (2023). Shallow groundwater: Monitoring wells SPM-1 and SPM-2 are used to monitor the western boundary of the Site. The MCL for arsenic is 0.05 mg/L and both SPM-1 and SPM-2 have shown compliance with this performance standard since 2004. In 2023, the arsenic concentrations for SPM-1 and SPM-2 were 0.0061 mg/L and 0.0016 mg/L, respectively. Monitoring wells SPM-3, SPM-4, and SPM-5 are used to monitor groundwater discharge to Little Cottonwood Creek and the performance standard for arsenic is the ACL of 5.0 mg/L. As of 2005, all analytical data for dissolved arsenic in the groundwater are below the performance standard. In 2023 the arsenic concentration for SPM-3 was 0.0202 mg/L; for SPM-4 the arsenic concentration was 0.0574; and the arsenic concentration for SPM-5 was 0.149 mg/L. Intermediate groundwater: Monitoring wells IPM-1, IPM-2, IPM-3, and IPM-5 (replacement well for IPM-4 that was abandoned in 2016) are used to monitor the intermediate aquifer. Monitoring wells IPM-1, IPM-2, IPM-3, and IPM-5 show arsenic concentrations below the MCL of .05 mg/L. In accordance with the Sampling & Analysis Plan (Ramboll, 2016), surface water sampling is conducted once every five years. Surface water sampling was performed in 2021 at three locations: the upstream boundary of the Site (SW-13), within the Site boundary (SW-15), and downstream of the Site boundary (SW-5) (Figure 4). In addition to sampling, Ramboll prepares a Data Evaluation Report every three years that compares surface water and groundwater monitoring data with applicable performance standards using the statistical standards developed in the RDR. The report evaluates the attainment of performance standards for groundwater and surface water and evaluates the effectiveness of Monitored Natural Attenuation. According to the 2021 Data Evaluation Report, the following performance standards have been achieved: surface water at the downstream point of compliance (SW-5); shallow groundwater at the western boundary (SPM-1 and SPM-2); and shallow groundwater in the vicinity of Little Cottonwood Creek (SPM-3, SPM-4, and SPM-5). The 2018 Data Evaluation Report analyzed trends in data from 2014 through 2017. The report indicated an increase in arsenic in the natural attenuation monitoring wells MW-10, MW-11, and MW-12. The report attributed the increase to turbidity and problems with the adjacent storm sewer system. However, the trend analysis from the 2021 Data Evaluation Report exhibited an increasing arsenic trend at the 95% confidence level in all three wells, with results at or above the MCL of 0.05 mg/L, which indicates that the arsenic concentrations in groundwater in the natural attenuation monitoring wells are not decreasing over time due to natural attenuation. Additionally, the 2021 Data Evaluation Report indicated that concentrations of arsenic have remained elevated at the repository monitoring well MW-3D. Overall, there is an increasing concentration trend downgradient of the parking repository as part of the Repository Detection Monitoring program. MW- 3D is the only well located directly downgradient of the parking repository, and its upgradient pair, MW-3U, does not exhibit the same increasing trend. • • 13 Site Inspection The inspection of the Site was conducted on September 13, 2023. In attendance were Maureen Petit (UDEQ), Sydney Chan (EPA), and Marc Sarmiento (EPA). The purpose of the inspection was to assess the protectiveness of the remedy. The barrier system appeared to be in very good condition; it appeared to be maintained in accordance with the SSOD and applicable plans. No significant problems were encountered. The physical integrity of the monitoring wells surface flush mounts were well-maintained. Inspections of the UTA and Costco parking areas showed minor cracks in the asphalt that are common due to use and wear and will be repaired in Spring 2024. The Site Inspection Checklist and photos are provided in Appendix D. V. TECHNICAL ASSESSMENT QUESTION A: Is the remedy functioning as intended by the decision documents? Question A Summary: The review of documents and results of the Site Inspection indicates that the remedies at the on-facility and off-facility areas are functioning as intended by the ROD. Continued groundwater monitoring is necessary to determine if arsenic concentrations are decreasing over time due to natural attenuation. Additional wells may be necessary to determine if the increasing trends observed are Site-related. Remedial Action Performance The selected remedy for the on-facility area was source control and MNA to achieve the RAO for on- facility groundwater, barrier placement to achieve the RAO for on-facility soil/smelter materials, and institutional controls. The stabilization and covering with barriers for Category II, III and IV contaminated materials achieve the RAOs by preventing exposure to arsenic-contaminated smelter/soils through direct contact or inhalation of air-borne dust. Because this is a containment remedy, maintenance of the Site focuses on the effectiveness of the remedy. Restrictive Easements prevent the construction of new wells or the use of existing wells for any purpose (except for monitoring wells). Groundwater and Surface water ACLs are being met, thus meeting the remedial goals in Little Cottonwood Creek. Implementation of Institutional Controls and Other Measures Restrictive easements prohibiting the construction of new wells or use of existing wells were developed associated with land use in the off-facility area. To protect the integrity of the on-facility area, Murray City created the SSOD with the passage of Ordinance 98-07 on April 14, 1998, and subsequently hired a development site coordinator to oversee the SSOD. The SSOD established the necessary public and private ICs to protect human health and the environment from the remaining contamination at the Site and to protect the integrity of current and future barriers/caps. The SSOD specifically requires a development permit to be obtained that includes a grading and drainage plan; a monitoring and maintenance plan to assure all caps and barriers will be maintained; and prohibits the use of existing wells or construction of new wells. The SSOD prevents residential and contact-intensive industrial land use and requires maintenance of the barriers and controls. 14 To ensure that the ordinance is being properly administrated and enforced by the City, UDEQ meets with City representatives regularly to discuss and answer questions related to new construction development and compliance with the SSOD. QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? Question B Summary: The current soil cleanup levels selected in the ROD were based on the estimated risks defined in BHHRA (1997). The on-facility surface soil concentration remediation level for industrial use is 5,600 ppm for lead and 1,200 ppm for arsenic. The off-facility surface soil lead concentration for industrial use is 5,600 ppm, and the soil lead concentration for residential use is 1,200 ppm. There have been changes to the exposure assumptions and toxicity information since the BHHRA was issued. When the Risk Assessments were conducted (1997), the risk models used a 10 micrograms per deciliter (µg /dL) blood lead level (BLL). This soil lead screening level was established so that a typical child or similarly exposed group of children would have an estimated probability of no more than 5 percent of exceeding a BLL of 10 µg/dL. The 10 µg/dL BLL target concentration is based (in part) on the 1991 Center for Disease Control’s (CDC) blood lead “level of concern.” In 2012, CDC accepted the recommendations of its Advisory Committee on Childhood Lead Poisoning Prevention that the “level of concern” be replaced by a reference value based on the 97.5th percentile of the National Health and Nutrition Examination Survey-generated BLL distribution in children 1-5 years old (i.e., 5µg/dL). In 2021, the CDC updated its blood lead reference value (BLRV) from 5µg/dL to 3.5 µg/dL in response to the Lead Exposure Prevention and Advisory Committee (LEPAC) recommendations. On January 17, 2024, EPA OLEM released the “Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities” (2024 Updated Soil Lead Guidance), which updates the residential soil lead screening level (RSL) and removal management level (RML) for the CERCLA and RCRA programs and provides additional guidance for setting residential lead preliminary remediation goals (PRGs) and cleanup levels. The 2024 Updated Soil Lead Guidance recommends that regions use the most current version of the Integrated Exposure Uptake Biokinetic (IEUBK) model, with 5 µg/dL as the 95th percentile target blood lead level and site-specific environmental data (e.g., lead concentrations in various media and bioavailability) to develop PRGs and cleanup levels for residential land use. If an additional source of lead (e.g., lead water service lines, lead-based paint, non-attainment areas where the lead concentrations exceed NAAQS) is identified, 2024 Updated Soil Lead Guidance recommends 3.5 µg/dL as the 95th percentile target blood lead level. The 2024 Updated Soil Lead Guidance also recommends that the EPA region adjust PRGs and cleanup levels to account for uncertainty, technical limitations (i.e., detection/quantification limits), and site-specific soil lead background. As discussed in previous FYR reports, the Maximum Contaminant Level (MCL) for arsenic changed from .05 mg/L to .01 mg/L and the arsenic criterion for aquatic wildlife (i.e. ambient water quality criteria) changed from 0.190 mg/L to 0.150 mg/L. Analytical data collected for groundwater from 2018- 2021 showed no arsenic concentrations above the MCL of 0.05 mg/L. Groundwater at the Site is not currently being used as a source of drinking water and ICs restricting groundwater use remain in place. Therefore, the remedy remains protective, despite the change to the MCL. 15 No new contaminants of concern or contaminant sources have been identified since the ROD and the commencement of the RA. There have been changes to the exposure assumptions and toxicity information since the document was issued. The ROD was developed prior to the EPA’s Risk Assessment Guidance for Superfund (RAGS) Part F (2009), and the exposure assumptions for the inhalation exposure pathway were conducted differently. The exposure metric that was used in the ROD and the BHHRA used inhalation concentrations that were based on ingestion rate and body weight (mg/kg)-day). The updated methodology uses the concentration of chemicals in the air, with the exposure metric of micrograms per cubic meter (ug/m3). The inhalation pathway for the site COCs, arsenic and lead, is minor compared to the soil ingestion pathway, which is the major risk factor at the Site. Revising the inhalation calculations to be consistent with the most recent EPA guidance would not change the current cleanup levels for the Site. The current land use and reasonably expected future land use has not changed. The ERA evaluated potential exposures of fish, birds, mallard ducks, frogs, and pocket gophers to smelter-related chemicals of concern within likely habitat areas. Given that the remedy for the Site includes capping of all exposed surface areas including wetlands, no ecological mitigation was warranted. QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? The boundaries of the off-facility area were excluded from the figures and maps of the third FYR (2014) and fourth FYR (2019) of the Site. As a result, the off-facility area has not been recognized as part of the Site, and development has occurred without consideration to contaminant exposure. The off-facility area is not protected from development by a soil ordinance, only groundwater restriction uses. The off- facility area is considered part of the Site boundary, per the ROD, and will be evaluated for any future development. 16 VI. ISSUES/RECOMMENDATIONS Issues and Recommendations Identified in the Five-Year Review: OU(s): Off-Facility Area Issue Category: Remedy Performance Issue: On January 17, 2024, the EPA issued Updated Soil Lead Guidance for CERCLA sites and RCRA Corrective Action Facilities that lowered recommended regional screening levels for lead-contaminated soil in residential areas. Recommendation:In accordance with the guidance, use new screening levels to determine whether further investigation is warranted and whether additional response actions are necessary for the remedy to remain protective. Affect Current Protectiveness Affect Future Protectiveness Party Responsible Oversight Party Milestone Date Yes Yes EPA EPA 8/14/2029 OU(s): Off-Facility Area Issue Category: Institutional Controls Issue: The off-facility area is not protected from development under a soils ordinance. Recommendation: Evaluate the off-facility area and determine whether additional ICS are required. Affect Current Protectiveness Affect Future Protectiveness Party Responsible Oversight Party Milestone Date Yes Yes EPA EPA 8/14/2029 OU(s): Off-Facility Area Issue Category: Remedy Performance Issue: MCL for arsenic changed from .05 mg/L to .01 mg/L effective January 2006. Recommendation: The UDEQ and the EPA evaluated the MCL change to determine if the new MCL for arsenic should be adopted. UDEQ and the EPA agreed that no change is necessary at this time and that any needed change will be evaluated again during the next five-year review period. Affect Current Protectiveness Affect Future Protectiveness Party Responsible Oversight Party Milestone Date No Yes EPA EPA 8/14/2029 17 OU(s): Off-Facility Area Issue Category: Remedy Performance Issue: Aquatic Life Ambient Water Quality Criteria for arsenic changed to 0.150 mg/l (4-day average) and 0.340 mg/l (1-hour average). Recommendation: The UDEQ and EPA evaluated the Aquatic Life Ambient Water Quality Criteria change to determine if the new water quality criteria for arsenic should be adopted. UDEQ and EPA agreed that no change is necessary at this time and that any needed change will be evaluated again during the next five-year review period. Affect Current Protectiveness Affect Future Protectiveness Party Responsible Oversight Party Milestone Date No Yes EPA EPA 8/14/2029 OTHER FINDINGS In addition, the following are recommendations that were identified during the FYR and may improve the management of O&M but do not affect current and/or future protectiveness: Murray City did not provide annual SSOD reports for 2021 and 2022 due to employee turnover. UDEQ met with Murray City in March 2023 and discussed the requirements outline in the SSOD. An Optimization Review of the Site is underway by a team of technical experts to ensure the remedy is protective and effective. The results of this review are expected to be finalized in 2024 and should be considered during the next five-year evaluation period. The boundaries of the off-facility area were excluded from the figures and maps of the third FYR (2014) and fourth FYR (2019) of the Site. As a result, the off-facility area has not been recognized as part of the Site and development has occurred without consideration to contaminant exposure. The off-facility area is within the Site boundary and will be considered for any future redevelopment. Residential properties located in the off-facility area will be re- evaluated under the 2024 Updated Soil Lead Guidance. • • • 18 VII. PROTECTIVENESS STATEMENT Sitewide Protectiveness Statement Protectiveness Determination: Protectiveness Deferred Planned Addendum Completion Date: 8/14/2029 Protectiveness Statement: A protectiveness determination of the remedy cannot be made at this time until further information is obtained. Further information will be obtained by applying the 2024 Updated Soil Lead Guidance for CERCLA sites and RCRA Corrective Action Facilities and using the lowered screening levels to determine whether further investigation is warranted and whether additional response actions are necessary for the remedy to remain protective. It is expected these steps could take approximately five years to complete, after which a protectiveness determination will be made. VIII. NEXT REVIEW The next five-year review report for the Murray Smelter Superfund Site is required five years from the completion date of this review. 19 APPENDIX A – REFERENCE LIST EPA Administrative Order on Consent for Removal Action with Asarco, Murray Smelter Site, September 1995. (SEMS# 373685) EPA, Baseline Ecological Risk Assessment, Former Murray Smelter Site, September, 1997, (SEMS# 373940) EPA, Baseline Human Health Risk Assessment, Murray Smelter, May, 1997. (SEMS# 373854) EPA, 2011. Preliminary Closeout Report, September, 2011. EPA, Superfund Record of Decision; Murray Smelter, UT, April, 1998. (SEMS# 374026) Hydrometrics, Inc., Site Characterization Report for Former Murray Smelter Site, August, 1996. (SEMS# 373865) MFG, Inc. Feasibility Study Report, Murray Smelter, August, 1997. (SEMS# 373943) MFG, Inc., Ground Water and Surface Water, Former Murray Smelter Site, April, 1998. (SEMS# 374030) MFG, Inc., Site Characterization Report, Murray Smelter, August, 1996. (SEMS# 373867) Murray City, 2019 Annual SSOD report, May 2020. Murray City, 2020 Annual SSOD Report, May 2021. Murray City, 2023 Annual SSOD Report, February 2024. Ramboll, Data Evaluation Report 2014-2017, February 2021. Ramboll, Data Evaluation Report 2018-2021, February 2022. Ramboll, 2019 Annual Monitoring Report, September 2019. Ramboll, 2020 Annual Monitoring Report, October 2020 Ramboll, 2021 Annual Monitoring Report, February 2022. (SEMS# 100014261) Ramboll, 2022 Annual Monitoring Report, December 2022. (SMES # 10014260) Ramboll, 2023 Annual Monitoring Report, October 2023. Ramboll, Sampling and Analysis Plan and Quality Assurance Project Plan, November 2016. (SEMS# 1846353) UDEQ, First Five-year Review Report for Murray Smelter Site, 2003. (SEMS# 2023649) UDEQ, Second Five-year Review Report for Murray Smelter Site, 2009. (SEMS# 1096482) UDEQ, Third Five-year Review Report for Murray Smelter Site, 2014. (SEMS# 1289300) UDEQ, Fourth Five-year Review Report for Murray Smelter Site, 2019. 20 APPENDIX B- SITE MAPS 21 ......... ~ -.; ;;; 11'1 ;I: I s !90W W5thAw E 5th .Ave "' 5 " s 1 .., ~ "' Col1on"1Qod r, e,,,s, CJ. .,; a ,I).¾ s ~ l "' ... ✓z_ ,i' ( AndenonAve ----· ~ ~mi "'i 0.1 Q ... .,, .. , -1an., r•n• a, ,, E .. VIAONMENTAL RESPONSE b REM E01ATt0N 1/.,,, .. s, .,. >/I Valley Center E.. Normandy ~ .8 3 11'1 11'1 ., j VI "~~ s; ~,,, ~ .:; ; j !! Murr.I) ~ "' 111 ES600s l CGCNO Off-Facility On-Facility Figure 1 Site Bourid=ries Mun 11'(Smelt.c1 RYeMYenr Re\•io:>w 22 7 • ' ~ r " t1->,11t, ,USNM .at.A.U1 ENVIAONHENT.._l. RESPONSE a REHEOIATIOH - LEGEND .. 0 .. --,,. -- --·--,1,l'A!lll,1•lE IIPiflAIOlll'f ~ ~•l#N9~~•ti.ttll:U" ~IIQIO'IU•·~Ol!YO'#lEOilrVtR>Y~ "' ~.~A.IU'E!tl • V.'l'IW •nt;IC<l"IO'lo lffllll'°""3 ♦ Jtf103m,,'V' ontt'OOla ~ ♦ flEfO'lflcr.vom:cntft~• ""'~ .. m-~~JOFtiie) • ,t~f VCllll'Cfl~ --l~W 10,.#000.:R!:H .. .. .. .. ... .. .. • ~ » ... "' ... ® ·-~ -7 ·i;,;;__~;i . • ~llR -i ... I .. -' .. ... .. ... "' .. Figure 2 Shallow Aquifer t,,tonitoring Well locations Murray Smeltel" Five-Yen Review 23 u,,,!J ...,_ •• .. , '" •D'I .. 1 GUA.~l!'t ENVIAONHEHTAL RESPONSE' & PEMEOtATI ON LfGEND ----OtHACILITY 801JNDARY V...§./Ji PARKlt~ REPOSITORY ~ ROADWAY REPOSITORY ·♦ INTERMEDIATE AQUIFER WELLS -LITTLE OOTTONIAIOODCREEK Figure 3 Intermediate Aquifer Monitoring Well l ocations Murray smelter Five•Year Review 24 Q U,., AJr, ~I"" ""''"0 •l'•1 , CIUA~l•V ~"'I E-NVIAOHHEHTAL IHSPOH5 E ,,.-: & REMEOJATI OH LEGEND ---ON--fACIUTY BOUNDARY ~ PARKI~ REPOSITORY ~ ROAr:IWAY REPOSITORY ♦ SURFACE WATER .. _ LITTLE COTTOIM'OODCREEK Figure 4 Surfue \'.'1tE:r S;mple locations Murra•; Sm:-her five-Year R,:•Jia,v 25 APPENDIX C- PUBLIC NOTICE AND COMMUNITY INTERVIEWS Murray Smelter Superfund Site Five-Year Review PUBLIC NOTICE FIVE YEAR REVIEW OF MURRAY SMELTER SUPERFUND SITE Salt Lake County The Utah Department of Environmental Quality, Division of Environmental Re- sponse and Remediation (UDEQ/DERR)-in cooperation with the U.S. Environmen- tal Protection Agency Region 8 (EPA)-is conducting the fifth Five-Year Review of the remedial actions performed at the Murray Smelter Superfund Site located in Murray, Salt Lake County, Utah. Site cleanup took place between 1995 and 2001. Cleanup activities included the disposal of arsenic and lead contaminated soils, the demolition of the smelter fa- ci lities and smokestacks, and placement of less contaminated soils into lined repos- itories capped by new roadways. Groundwater monitoring is ongoing. The 142-acre on-site facility was cleaned for reuse and redevelopment where a medical campus, light rail station, and retail stores now reside. Five-Year reviews are required by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) as contaminants remain in portions of the Site above levels that allow for unrestricted use and unlimited exposure. Five-Year Reviews are conducted to evaluate the site remedy and determine whether site con- ditions remain protective of human health and the environment. The Five-Year Review will include community interviews, a review of site docu- ments and data, including a site inspection to evaluate all remedy components. The review will be completed by August 2024. More information on the Murray Smelter Superfund Site is available online at: https://www.epa.gov/superfund/murray-smelter If you would like more information about the review or would like to participate in an interview, please contact: Maureen Petit UOEQ Project Manager Phone: (385) 391-8127 Email: mpetit@utah.gov Cave Allison U0EQ Community Involvement Phone: (385) 391-8143 Email: dallison@utah.gov Sydney Chan EPA Remedial Project Manager Phone: (303) 312-6691 Email:chan.sydney@epa.gov 26 Interview of Local Agencies Site Name: Murray Smelter EPA ID: UTD980951420 March 19, 2024 Type of Contact:Teleconference Call Contact Made By:Dave Allison and Maureen Petit, UDEQ-DERR. Person Contacted Name: Jim Blankenau, Environmental Program Manager, Mark Olsen, Facilities Manager, Garrett Petersen, Industrial Hygiene Director, Rick Clark, Ground Supervisor Organization: Intermountain Healthcare Medical Center, Property Owner Address: Intermountain Healthcare Corporate 36 S State Street Salt Lake City, Utah 84111 Phone: (801) 442-2000 1. Is your organization/department aware of the Murray Smelter Superfund site and the actions underway to address environmental contamination? UDEQ met with the following representatives from the Intermountain Health Center (IHC): Jim Blankenau, Environmental Engineer and Program Manager; Garrett Petersen, Industrial Hygienist; Mark Olsen, Facilities Manager; and Rick Clark, Ground Supervisor. Each representative was familiar with the extent of the institutional controls and Site cleanup history. 2. What’s your overall impression (your general sentiment) of the actions performed at the Murray Smelter Superfund Site? The IHC representatives expressed satisfaction with the response work that has been done at the Site and the institutional controls in place. They discussed the response work that has been undertaken to address the environmental contamination at the Site, including the removal of soil during the construction of a new building. They also mentioned the presence of institutional controls, the appropriateness of the remedy, and their comfort with them. 3. Does your office conduct routine communications and/or activities (site visits, inspections, reporting activities, participation in meetings, etc.) for the Murray Smelter Superfund Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. The IHC representatives said there isn’t any formal reporting requirements. The IHC hospital representatives mentioned that they have regular communication with Murray City and provide information as requested which is used for an annual report of Site activities. 4. Are you aware of any community concerns regarding the Murray Smelter Superfund Site or its operation and administration? If so, please give details. The IHC representatives said they were not aware of any specific community concerns related to the site or its impacts on development, land use, water use, or historical preservation. 5. Over the past five years, have there been any complaints, violations, or other incidents (e.g., vandalism, trespassing, or emergency responses) at or related to the Murray Smelter Superfund Site requiring your office to respond? If so, please give details of the events and results of the response. The hospital representatives said they are not aware of any unusual activities or incidents at the site. They mentioned an incident where a sump connected to the hospital's cooling towers had a hole, 27 causing water intrusion into the utility tunnel. The water collected had elevated levels of arsenic, which had to be disposed of properly. They reported the incident to the EPA, the state, and Murray City. They also mentioned the hospital regularly performs general maintenance with crack sealing and slurry coating on the parking lot. 6. Do you feel well informed about the site’s activities and progress over the last five years? Do you know how to contact the Environmental Protection Agency if you have questions or concerns about the Murray Smelter Superfund Site? The IHC hospital representatives said that communication with the EPA and Murray City has been effective, and they feel well-informed about the activities and progress at the Site. The IHC representatives mentioned that they have access to information about the Site and keep records of their activities and know how to contact the EPA and UDEQ with any questions or concerns. The IHC representatives said they are in fairly close contact with Murray City and understand the SSOD permitting process. 7. Over the past five years, have there been any changes in land use surrounding the Murray Smelter Superfund Site? Are you aware of potential future changes in land use?The IHC representatives said there is a fairly large construction project ongoing. The IHC expansion project is an expansion of the Central lab facility and is nearing completion. A large amount of soil was removed to construct the building. The soil was sampled, and approved for disposal from both the state and EPA. The hospital representatives mentioned that they do not foresee any major development activities at the Site within the next five years. 8. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation (institutional controls)? If so, what types of future problems do you think (1) could occur; or (2) would concern you and/or your department? Overall, the hospital representatives expressed confidence in the remediation efforts at the Murray Smelter Superfund Site and their ability to operate within the Site's requirements. They recommended consideration for a more streamlined permitting process for smaller projects with in the SSOD ordinance. IHC expressed satisfaction with their communication with UDEQ, EPA and Murray City. 28 Murray Smelter Superfund Site Five-Year Review Interview of Local Agencies Site Name: Murray Smelter EPA ID: UTD980951420 March 20, 2024 Type of Contact: Teleconference Call Contact Made By: Dave Allison and Maureen Petit, UDEQ-DERR. Person Contacted Name: Phillip Markham, Director - Community & Economic Development Trae Stokes, City Engineer Organization: Murray City Community & Economic Development and Engineering Department Address: Murray City 10 East 4800 South Murray, UT 84107 Phone:(801) 270-2440 1. Is your organization/department aware of the Murray Smelter Superfund Site and the actions underway to address environmental contamination? Trae Stokes, City Engineer, and Philip Markham, Community and Economic Development Director for Murray City, said they have years of experience with the Site and corresponding responsibilities and have knowledge of the cleanup history. Stokes and Markham discussed their roles in overseeing permits for work on the site, ensuring compliance with institutional controls, and authoring annual reports. Stokes said, as the City Engineer, he has been involved with the Site since the beginning of his career, focusing on engineering aspects such as roadways and utilities. Markham said he oversees the administration of the SSOD (Smelter Site Overlay District) ordinance, coordinates with public works and other departments, and has been involved with the Site since the smokestacks were taken down. 2. What’s your overall impression (your general sentiment) of the actions performed at the Murray Superfund Site? Stokes discussed the permitting process in place to monitor activities on the Site, including excavation work and construction. Markham said he is responsible for coordinating with public works, authoring the annual report, and ensuring compliance with stormwater regulations. Murray City has implemented a robust permitting process under the SSOD and keeps a close eye on the Site for any excavation work or construction that might disturb existing barriers. 3.Does your office conduct routine communications and/or activities (site visits, inspections, reporting activities, participation in meetings, etc.) for the Murray Smelter Superfund Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. Both said there are not any scheduled communications or regular reporting tasks for the Site outside of a required annual report. Markham compiles a detailed annual report from property owners on the Site, including activities and projects undertaken and provides the report to UDEQ and the U.S.EPA. 4. Are you aware of any community concerns regarding the Murray Smelter Superfund Site or its operation and administration? If so, please give details. Stokes and Markham said the community has largely moved on from viewing the area as a Superfund Site. Now, seeing it as a developed area with businesses like Costco and IHC. The community is generally not concerned with the Site as it's now known for its successful redevelopment rather than its history as a smelter site. 5. Over the past five years, have there been any complaints, violations, or other incidents (e.g., vandalism, trespassing, or emergency responses) at or related to the Murray Smelter Superfund 29 Site requiring your office to respond? If so, please give details of the events and results of the response. Stokes and Markham said nothing major has happened at the Site requiring an emergency response, more general maintenance issues. Stokes recounted a few minor incidents where contractors breached the Site's protocols but were quickly managed, emphasizing the robust permit review process and the city's proactive monitoring. Major construction projects in the last five years were limited, with the most significant being Intermountain Health Care's 5-acre lab expansion. 6. Do you feel well informed about the site’s activities and progress over the last five years? Do you know how to contact the Environmental Protection Agency if you have questions or concerns about the Murray Smelter Superfund Site? Stokes and Markham said that Murray City is well-informed about Site activities and has the necessary contacts at the EPA and UDEQ for any concerns. Both said the EPA and UDEQ are seen as responsive and effective in communication with the public and stakeholders 7. Over the past five years, have there been any changes in your department’s policies or regulations that might impact the Superfund Site from a perspective of land use, water rights, redevelopment, and site management? There was a discussion about the off-facility areas and how they might be impacted by new EPA screening levels for lead. The residential areas near the site have not seen significant redevelopment, maintaining their character as affordable housing areas. Stokes inquired about the intent of the EPA's optimization report and its implications for the Site's future management. UDEQ clarified that the report aims to assess natural attenuation success but indicated that the agencies are unlikely to step back from the Site due to recent changes in lead policy. UDEQ said a Site visit focusing on the residential section and off-facility area is planned, with a focus on the new lead policy implications. There was also discussion about whether smaller projects, like repairing a lamp post, should require the same permitting process. Stokes and Markham expressed that the current process is working well, but they are open to discussing potential streamlining for minor works. 8. Over the past five years, have there been any changes in land use surrounding the Murray Smelter Superfund Site? Are you aware of potential future changes in land use? Stokes and Markham said no significant policy or land use changes have occurred at the Site. There is a Utah Transit Authority (UTA) planning document in the works for the Murray Central Station area which will consider the smelter site implications. 9. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation (institutional controls)? If so, what types of future problems do you think (1) could occur; or (2) would concern you and/or your department? Stokes and Markham said they had an appreciation for the collaborative relationship between Murray City and regulatory agencies, with acknowledgment of the importance of maintaining effective communication and compliance. Both expressed their commitment to continuing the effective management of the Murray Smelter Superfund Site. 30 Murray Smelter Superfund Site Five-Year Review Interview of Local Agencies Site Name: Murray Smelter EPA ID: UTD980951420 April 2, 2024 Type of Contact: Teleconference Call Contact Made By:Dave Allison and Maureen Petit, UDEQ-DERR. Person Contacted Name: Mark Taggart and Sean Thal, Environmental Compliance Managers Organization: Utah Transit Authority – Property Owner Address: Utah Transit Authority 669 West 200 South Salt Lake City, UT 84101 Phone: (801)743-3882 Website: www.rideuta.com 1. Is your organization/department aware of the Murray Smelter Superfund site and the actions underway to address environmental contamination? Sean Thal and Mark Taggart are Environmental Compliance Managers with the Utah Transit Authority (UTA) and have been with UTA for two and a half years and almost two years, respectively. The UTA Managers said they are aware of the Site's Superfund history and the required institutional controls in accordance with the Murray City Smelter Site Overlay District (SSOD). In 2000, UTA built a light-rail station on 6.5 acres on the southern end of the former Murray Smelter Site. Lead and arsenic soils were encapsulated under portions of the parking lot of the UTA property in an on-site repository. 2. What’s your overall impression (your general sentiment) of the actions performed at the Murray Smelter Superfund Site? The UTA Managers said the remedy is performing as expected, working great, and there have been no issues or concerns. The Murray Central Station is being maintained and inspections are conducted. UTA Managers said they have not received any negative reports from their maintenance personnel or neighboring properties. The UTA resurfaced the entire eastern parking lot last year. The UTA Managers said they do inspections on a regular basis, particularly after a rainstorm, and drive the whole area as well as take pictures. Construction projects are planned and executed in compliance with permits and regulations. UTA Managers said even small short-term construction activities, such as a switch-light pole placement and landscaping sprinkler repair, are subject to the site institutional control permits. 3. Does your office conduct routine communications and/or activities (site visits, inspections, reporting activities, participation in meetings, etc.) for the Murray Smelter Superfund Site? If so, please briefly summarize the purpose and results of these communications and/or activities over the past several years. The UTA Managers said they do quarterly inspections and they have not encountered any issues or violations. They also share information with Murray City for their annual SSOD report on the Site. Murray City keeps UTA informed of any developments or changes related to the Site. 4. Are you aware of any community concerns regarding the Murray Smelter Superfund Site or its operation and administration? If so, please give details. The UTA Managers said they are not aware of any community health or environmental concerns regarding the Site or its operation. The UTA Managers said the Site's history and cleanup have been well-documented, and UTA is transparent about it. 31 5. Over the past five years, have there been any complaints, violations, or other incidents (e.g., vandalism, trespassing, or emergency responses) at or related to the Murray Smelter Superfund Site requiring your office to respond? If so, please give details of the events and results of the response. UTA complies with Murray City's regulations and reports quarterly inspections. There have been no violations, incidents, or emergency responses on the Site in the last five years. 6. Do you feel well informed about the site’s activities and progress over the last five years? Do you know how to contact the Environmental Protection Agency or UDEQ if you have questions or concerns about the Murray Smelter Superfund Site? The UTA Managers said they are well- informed about the site's activities and progress through regular communication. Most of their communications have been with Murray City and they were provided with updated contact information for the U.S. EPA Region 8 and UDEQ Project Managers as staff turnover has occurred since the last Five-Year Review. 7. Over the past five years, have there been any changes in land use surrounding the Murray Smelter Superfund Site? Are you aware of potential future changes in land use? The UTA Managers said there were not any land use changes and said there are plans for an expansion of a roundabout near their property but no other significant changes. The UTA Managers said the construction of a bus rapid transit system needed the roundabout to be larger and would not encroach on the buried material capped underneath the parking lot. The UTA Managers also wanted access to any updated maps for the site to reflect the site changes from the last Five-Year Review accurately. 8. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation (institutional controls)? If so, what types of future problems do you think (1) could occur; or (2) would concern you and/or your department? The UTA Managers expressed their satisfaction with the Site's management and operation and have no major concerns. They mentioned that they had good communication with Murray City and the environmental agencies ensuring ongoing communication and cooperation with the UTA. 32 APPENDIX D- SITE INSPECTION CHECKLIST AND PHOTOS 33 Site Inspection Photograph Log Photo No. 1 9/13/2023 Description: Monitoring Well-3D located in UTA parking lot Photo No. 2 9/13/2023 Description: Monitoring Well-3U Photo No. 3 9/13/2023 34 Description: Monitoring Well-2D Photo No. 4 9/13/2023 Description: The new switches installed along the tracks in the Spring of 2023 Photo No. 5 9/13/2023 35 Description: Switches and electrical installed along the tracks in Spring 2023 Photo No. 6 9/13/2023 Description: Cracks in the UTA parking lot, cracks are sealed annually Photo No. 7 9/13/2023 36 Description: Cracks in the UTA parking lot, cracks are sealed annually Photo No. 8 9/13/2023 Description: Conduit boring from Vine Street to the end of the parking lot Photo No. 9 9/13/2023 37 Description: The Intermountain Health expansion building Photo No. 10 9/13/2023 Description: Covered soil stockpile on Site near the expansion building Photo No. 11 9/13/2023 38 Description: Monitoring Well-1U in the Grandview Parking Lot of IHC 39 I. SITE INFORMATION Site name: Murray Smelter Superfund Site Date of inspection: September 13, 2023 Location and Region: Murray City, Salt Lake County, Region 8 EPA ID: UTD980951420 Agency, office, or company leading the five-year review: DERR Weather/temperature: 70 degrees, mostly cloudy, no wind Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other______________________________________________________________________ _____________________________________________________________________________ Attachments: Inspection team roster attached Site map attached II. INTERVIEWS (Check all that apply) 1. O&M site manager _______Trae Stokes_____________________ ______________________ ____________ Name Title Date Interviewed at site at office by phone Phone no. ______________ Problems, suggestions; Report attached ______Conducting biannual inspections on time__________________________________________ __________________________________________________________________________________ 2. O&M staff ____________________________ ______________________ ____________ Name Title Date Interviewed at site at office by phone Phone no. ______________ Problems, suggestions; Report attached _______________________________________________ __________________________________________________________________________________ 00 00 00 □ 00 □ □ □ □ □ 00 IX) □ □ □ □ □ □ □ 40 3.Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply. Agency ____________________________ Contact ____________________________ __________________ ________ ____________ Name Title Date Phone no. Problems; suggestions; Report attached _______________________________________________ __________________________________________________________________________________ Agency ____________________________ Contact ____________________________ __________________ ________ ____________ Name Title Date Phone no. Problems; suggestions; Report attached _______________________________________________ __________________________________________________________________________________ Agency ____________________________ Contact ____________________________ __________________ ________ ____________ Name Title Date Phone no. Problems; suggestions; Report attached _______________________________________________ __________________________________________________________________________________ Agency ____________________________ Contact ____________________________ __________________ ________ ____________ Name Title Date Phone no. Problems; suggestions; Report attached _______________________________________________ __________________________________________________________________________________ 4. Other interviews (optional) Report attached. □ □ □ □ □ 41 III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) 1. O&M Documents O&M manual Readily available Up to date N/A As-built drawings Readily available Up to date N/A Maintenance logs Readily available Up to date N/A Remarks__________________________________________________________________________ ____________________________________________________________________ 2. Site-Specific Health and Safety Plan Readily available Up to date N/A Contingency plan/emergency response plan Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. O&M and OSHA Training Records Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 4. Permits and Service Agreements Air discharge permit Readily available Up to date N/A Effluent discharge Readily available Up to date N/A Waste disposal, POTW Readily available Up to date N/A Other permits__Building___________________ Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 5. Gas Generation Records Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 6. Settlement Monument Records Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 7. Groundwater Monitoring Records Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 8. Leachate Extraction Records Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 9. Discharge Compliance Records Air Readily available Up to date N/A Water (effluent) Readily available Up to date /A Remarks__________________________________________________________________________ _________________________________________________________________________________ 10. Daily Access/Security Logs Readily available Up to date N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ !RI !RI !RI □ !RI !RI !RI □ □ □ □ □ □ □ !RI □ □ □ !RI □ □ !RI □ □ □ !RI □ □ □ !RI □ □ □ !RI !RI □ !RI □ □ □ !RI □ !RI □ D !RI □ □ □ !RI □ □ □ !RI □ □ □ !RI □ □ !RI 42 IV. O&M COSTS 1. O&M Organization State in-house Contractor for State PRP in-house Contractor for PRP Federal Facility in-house Contractor for Federal Facility Other__________________________________________________________________________ _________________________________________________________________________________ 2. O&M Cost Records Readily available Up to date Funding mechanism/agreement in place Original O&M cost estimate____________________ Breakdown attached Total annual cost by year for review period if available From__________ To__________ __________________ Breakdown attached Date Date Total cost From__________ To__________ __________________ Breakdown attached Date Date Total cost From__________ To__________ __________________ Breakdown attached Date Date Total cost From__________ To__________ __________________ Breakdown attached Date Date Total cost From__________ To__________ __________________ Breakdown attached Date Date Total cost 3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: __________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A A. Fencing 1. Fencing damaged Location shown on site map Gates secured N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ B. Other Access Restrictions 1. Signs and other security measures Location shown on site map N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ □ □ □ IX] □ □ □ □ □ IX] □ □ □ □ □ □ IX] □ □ □ IX] □ IX] 43 C. Institutional Controls (ICs) 1. Implementation and enforcement- Murray City responsible for implementing ICs Site conditions imply ICs not properly implemented Yes No N/A Site conditions imply ICs not being fully enforced Yes No N/A Type of monitoring (e.g., self-reporting, drive by) Biannual inspections of barriers Frequency November and May Responsible party/agency Murray City Contact Trae Stokes Phone no. (801) 270-2440 Reporting is up-to-date Yes No N/A Reports are verified by the lead agency Yes No N/A Specific requirements in deed or decision documents have been met Yes No N/A Violations have been reported Yes No N/A Other problems or suggestions: Report attached _________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ 2. Adequacy ICs are adequate ICs are inadequate N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ D. General 1. Vandalism/trespassing Location shown on site map No vandalism evident Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Land use changes on site N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Land use changes off site N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ VI. GENERAL SITE CONDITIONS A. Roads Applicable N/A 1. Roads damaged Location shown on site map Roads adequate N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ B. Other Site Conditions Remarks. Some cracks observed on UTA Parking lot. Cracks are sealed annually. _____________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ □ !RI □ □ !RI □ !RI □ □ □ □ !RI □ □ !RI □ □ !RI □ !RI □ □ □ !RI !RI !RI !RI □ □ !RI □ 44 VII. LANDFILL COVERS Applicable N/A A. Landfill Surface 1. Settlement (Low spots) Location shown on site map Settlement not evident Areal extent______________ Depth____________ Remarks____________________________________________________________ __________________________________________________________________ 2.Cracks Location shown on site map Cracking not evident Lengths____________ Widths___________ Depths__________ Remarks___Some cracks in UTA and Costco parking lots, cracks are sealed annually. 3. Erosion Location shown on site map Erosion not evident Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 4. Holes Location shown on site map Holes not evident Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 5. Vegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs (indicate size and locations on a diagram) Remarks___Grass and landscape established and well maintained._______________________________________________________________________ _________________________________________________________________________________ 6. Alternative Cover (armored rock, concrete, etc.) N/A Remarks____Note existing buildings, parking lots, and paved roads act as barriers.______________________________________________________________________ _________________________________________________________________________________ 7. Bulges Location shown on site map Bulges not evident Areal extent______________ Height____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 8. Wet Areas/Water Damage Wet areas/water damage not evident Wet areas Location shown on site map Areal extent______________ Ponding Location shown on site map Areal extent______________ Seeps Location shown on site map Areal extent______________ Soft subgrade Location shown on site map Areal extent______________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 9. Slope Instability Slides Location shown on site map No evidence of slope instability Areal extent______________ Remarks__________________________________________________________________________ _________________________________________________________________________________ B. Benches Applicable N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) IX) □ □ IX) □ □ IX) □ IX) □ □ IX) □ □ □ IX) IX) □ □ □ □ □ □ □ □ □ □ IX) □ IX) 45 1.Flows Bypass Bench Location shown on site map N/A or okay Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Bench Breached Location shown on site map N/A or okay Remarks__________________________________________________________________________ _________________________________________________________________________________ 3.Bench Overtopped Location shown on site map N/A or okay Remarks__________________________________________________________________________ _________________________________________________________________________________ C. Letdown Channels Applicable N/A (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.) 1. Settlement Location shown on site map No evidence of settlement Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Material Degradation Location shown on site map No evidence of degradation Material type_______________ Areal extent_____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Erosion Location shown on site map No evidence of erosion Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 4. Undercutting Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 5. Obstructions Type_____________________ Areal extent______________ Size____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 6. Excessive Vegetative Growth Type____________________ Areal extent______________ Remarks__________________________________________________________________________ _________________________________________________________________________________ D. Cover Penetrations N/A □ □ □ □ □ □ □ ~ □ □ □ □ □ □ □ Location shown on site map □ No evidence of undercutting □ No obstructions □ Location shown on site map □ No evidence of excessive growth □ Vegetation in channels does not obstruct flow □ Location shown on site map □ Applicable @ 46 1. Gas Vents N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Gas Monitoring Probes N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Monitoring Wells (within surface area of landfill) Properly secured/locked Functioning Routinely sampled Good condition Remarks___________________________________________________________ _________________________________________________________________ 4. Leachate Extraction Wells N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 5. Settlement Monuments Routinely surveyed Remarks__________________________________________________________________________ _________________________________________________________________________________ E. Gas Collection and Treatment N/A 1. Gas Treatment Facilities N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Gas Collection Wells, Manifolds and Piping Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) N/A Remarks__________________________________________________________________________ _________________________________________________________________________________ F. Cover Drainage Layer N/A □ Active □ Passive □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ Evidence of leakage at penetration □ Needs Maintenance @ □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ Evidence of leakage at penetration □ Needs Maintenance @ @ @ @ @ □ Evidence ofleakage at penetration □ Needs Maintenance □NIA □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ Evidence of leakage at penetration □ Needs Maintenance @ □ Located @ □NIA □ Aoolicable @ □ Flaring □ Thermal destruction □ Collection for reuse □ Good condition □ Needs Maintenance @ □ Good condition □ Needs Maintenance □ Good condition □ Needs Maintenance @ □ Applicable @ 47 1. Outlet Pipes Inspected Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Outlet Rock Inspected Remarks__________________________________________________________________________ _________________________________________________________________________________ G. Detention/Sedimentation Ponds N/A 1. Siltation Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Erosion Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Outlet Works Remarks__________________________________________________________________________ _________________________________________________________________________________ 4. Dam Remarks__________________________________________________________________________ _________________________________________________________________________________ H. Retaining Walls N/A 1. Deformations Deformation not evident Horizontal displacement____________ Vertical displacement_______________ Rotational displacement____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Degradation Remarks__________________________________________________________________________ _________________________________________________________________________________ I. Perimeter Ditches/Off-Site Discharge N/A 1. Siltation Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Vegetative Growth Areal extent______________ Type____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ □ Functioning □NIA □ Functioning □NIA □ Applicable @ □NIA □ Siltation not evident □ Erosion not evident □ Functioning □NIA □ Functioning □NIA □ Aoolicable @ □ Location shown on site map □ □ Location shown on site map □ Degradation not evident □ Applicable @ □ Location shown on site map □ Siltation not evident □ Location shown on site map □NIA □ Vegetation does not impede flow 48 3. Erosion Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 4. Discharge Structure Remarks__________________________________________________________________________ _________________________________________________________________________________ VIII. N/A 1. Settlement Settlement not evident Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Performance Monitoring Type of monitoring__________________________ Frequency_______________________________ Head differential__________________________ Remarks__________________________________________________________________________ _________________________________________________________________________________ IX. N/A A. Groundwater Extraction Wells, Pumps, and Pipelines N/A 1. Pumps, Wellhead Plumbing, and Electrical Remarks__________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ 2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Spare Parts and Equipment Remarks__________________________________________________________________________ _________________________________________________________________________________ B. Surface Water Collection Structures, Pumps, and Pipelines N/A 1. Collection Structures, Pumps, and Electrical Remarks__________________________________________________________________________ _________________________________________________________________________________ □ Location shown on site map □ Erosion not evident □ Functioning □NIA VERTICAL BARRIER WALLS □ Aoolicable 0 □ Location shown on site map □ □ Performance not monitored □ Evidence of breaching GROUNDWATER/SURF ACE WATER REMEDIES □ Aoolicable 0 □ Aoolicable 0 □ Good condition □ All required wells properly operating □ Needs Maintenance □ NIA □ Good condition □ Needs Maintenance □ Readily available □ Good condition□ Requires upgrade □ Needs to be provided □ Aoolicable 0 □ Good condition □ Needs Maintenance 49 2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Spare Parts and Equipment Remarks__________________________________________________________________________ _________________________________________________________________________________ C. Treatment System N/A 1. Treatment Train (Check components that apply) Filters_________________________________________________________________________ surface water treated annually________________________ Remarks__________________________________________________________________________ _________________________________________________________________________________ 2. Electrical Enclosures and Panels (properly rated and functional) Remarks__________________________________________________________________________ _________________________________________________________________________________ 3. Tanks, Vaults, Storage Vessels Remarks__________________________________________________________________________ _________________________________________________________________________________ 4. Discharge Structure and Appurtenances Remarks__________________________________________________________________________ _________________________________________________________________________________ 5. Treatment Building(s) Remarks__________________________________________________________________________ _________________________________________________________________________________ □ Good condition □ Needs Maintenance □ Readily available □ Good condition□ Requires upgrade □ Needs to be provided □ Aoolicable @ □ Metals removal □ Oil/water separation □ Bioremediation □ Air stripping □ Carbon adsorbers □ □ Additive (e.g., chelation agent, flocculent) □ Others □ Good condition □ Needs Maintenance □ Sampling ports properly marked and functional □ Sampling/maintenance log displayed and up to date □ Equipment properly identified □ Quantity of groundwater treated annually □ Quantity of □NIA □ Good condition □ Needs Maintenance □NIA □ Good condition □ Proper secondary containment □ Needs Maintenance □NIA □ Good condition □ Needs Maintenance □NIA □ Good condition ( esp. roof and doorways) □ Needs repair □ Chemicals and equipment properly stored 50 6. Monitoring Wells (pump and treatment remedy) condition Remarks__________________________________________________________________________ _________________________________________________________________________________ D. Monitoring Data 1. Monitoring Data Is routinely submitted on time 2. Monitoring data suggests: x Groundwater plume is effectively contained D. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy) Functioning Routinely sampled All required wells located Remarks__________________________________________________________________________ _________________________________________________________________________________ X. OTHER REMEDIES If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XI. OVERALL OBSERVATIONS A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.). Remedy is capping with barriers to eliminate exposure pathway and monitored natural attenuation of groundwater. The remedy is functioning as designed. Institutional controls are in place that do not allow installation of new wells or use of existing wells. Groundwater monitoring/sampling is conducted on an annual basis. B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. O&M activities are adequate and remedy is currently protective. C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future. None noted during this five-year review D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None noted. □ Properly secured/locked □ Functioning □ Routinely sampled □Good □ All required wells located □ Needs Maintenance □NIA @ □ Is of acceptable quality □ Contaminant concentrations are declininj!; □ Properly secured/locked [&I [&I □ Good condition [&I □ Needs Maintenance □NIA